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    July 20, 2026   CircularsFEMA
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    July 20, 2026   Case LawsCustoms
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    July 20, 2026   Circulars FEMA
    Special Rupee Vostro Accounts enable INR trade settlement and permissible cross-border transactions under consolidated operational instructions.
    July 20, 2026   Case Laws GST
    Natural justice breach from portal-only notice required restoration of the GST appeal for merits adjudication without further pre-deposit.
    July 20, 2026   Case Laws GST
    Advance-ruling jurisdiction excludes completed transactions and cannot affirm tax positions already implemented in statutory returns.
    July 20, 2026   Case Laws Income Tax
    Annual shipping income assessment option challenged alongside separate vessel-wise assessments, with recovery stayed pending writ petition disposal.
    July 20, 2026   Case Laws Income Tax
    Operating lease ownership supports depreciation despite lessee registration, while undecided maintenance-charge grounds require fresh determination.
    July 20, 2026   Case Laws Income Tax
    Statutory refund interest requires correction of short computation and compensation where admitted interest remains unpaid through administrative delay.
    July 20, 2026   Case Laws Income Tax
    Refund adjustment against a subsisting stayed tax demand is unsustainable; the refund must be restored with applicable interest.
    July 20, 2026   Case Laws Income Tax
    Software licensing ancillary services and deemed Indian accrual are assessed under principles governing technical-service income.
    July 20, 2026   Case Laws Income Tax
    Charitable donation refunds need not defeat exemption where no donor benefit arises and funds remain applied charitably.
    July 20, 2026   Case Laws Income Tax
    Transfer-pricing adjustments for project business and intra-group services were remanded for fresh consideration under DRP directions.
    July 20, 2026   Case Laws Income Tax
    Article 8 aircraft-operation exemption excludes independent ground handling and engineering service receipts lacking qualifying airline-pool participation.
    July 20, 2026   Case Laws Income Tax
    Form 26A compliance protects interest expenditure where portal delays are not attributable to the payer and payees have paid tax.
    July 20, 2026   Case Laws Income Tax
    Section 87A rebate covers short-term capital gains tax under the new regime before later special-rate restrictions apply.
    July 20, 2026   Case Laws Income Tax
    Defective penalty notices and bona fide claims can invalidate penalties for disputed tax disallowances and under-reporting.
    July 20, 2026   Case Laws Income Tax
    Specific statutory charge in undisclosed-income penalty notices is essential; an unspecified penalty limb invalidates the proceedings.
    July 20, 2026   Case Laws Income Tax
    Doctrine of mutuality protects member-funded co-operative society surpluses, while timely audited returns avoid late-filing fee.
    July 20, 2026   Case Laws Income Tax
    Transfer under joint development agreements requires enforceable, irrevocable divestment of property rights before capital gains can arise.
    July 20, 2026   Case Laws Income Tax
    Bad-debt write-offs and reconciled contract receipts cannot support revision where assessment records show adequate enquiry.
    July 20, 2026   Case Laws Customs
    Binding detention-cum-waiver certificates require compliance, supporting conditional interim release of perishable imported goods despite detention charges.
    July 20, 2026   Case Laws Customs
    Food-safety sampling requires FSSAI authorisation, while Customs retains separate powers for revenue, classification and import-compliance purposes.

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      Home› Highlights › Income Tax › 2015 › October, 2015 › This
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      Income Tax

      Attribution of profits out of the sales made by the head office...

      India Branch's 20% Gross Profit Rate Unjustified; TPO Accepts Head Office's 8.81% Rate as Reasonable.

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      Income TaxOctober 22, 2015Case LawsAT
      Attribution of profits out of the sales made by the head office - the TPO has accepted the gross profit rate declared at 8.81%. In such a situation, acceptance of gross profit attribution of India Branch @ 20% does not inbspire confidence. - AT
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